QUICK GUIDE TO COMPLIANCE
User Ensure professional / industrial use only products cannot be purchased by general public.
Adverts Advertisement/website that allows purchase by consumers shows hazard of the product.
Labels Product labelled to CLP with correct label elements.
SDS For hazardous products proactively provide an up to date Safety Data Sheet (SDS) for all products.
Transport If the product meets the definition of dangerous goods, consult a DGSA.
Shipping When shipping through a carrier, ensure relevant packaging is used and labelling is displayed on outer packaging, in accordance with the UN number of the product and mode of transportation.
Ensure solvent-based paints are not sent by Royal Mail
When water-based paints in containers > 150 ml are not sent by Royal Mail
Do not ship by air (unless fully compliant).
Check with your carrier whether they ship paint.
The British Coatings Federation is the trade association representing the UK’s manufacturers of paint, coatings, inks and wallcoverings. This information note summarises the legal position on the offer, sale and shipment of paints and coatings, for sale via the internet.
BCF members are committed to supplying products that are in compliance with all relevant laws in the countries that they operate. However, all companies selling paints online and shipping to customers should be meeting the levels of compliance as set out in this note.
If you have concerns that a company may be noncompliant, you may raise this with the BCF who will be happy to investigate the matter. Alternatively, your concerns can be brought to the attention of the HSE via crdcompliance@hse.gsi.gov.uk
More detailed information on this topic is available online. Visit the BCF PaintSafe webpage:
The information in this note is believed at the time of writing to be true and accurate. It is a summary and should be considered in conjunction with the original legislation. All liability for loss or damage however arising from use of the information provided in this guidance (whether directly or indirectly) is hereby excluded to the fullest extent permitted by law.
© BCF 2025
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ADVERTISING, MARKETING AND SELLING GOODS ONLINE
Can I sell the paint to consumers?
Some industrial paints and coatings contain chemical substances that make them illegal to sell to the general public. Check the label or safety data sheet, SDS, before supplying.
You should have safeguards and checks in place to prevent the general public ordering such goods through on-line stores.
Is the paint suitable for the end-use?
Paints for buildings and vehicle refinish are subject to the ‘paints directive’ (2004/42/EC) which controls what paints can be sold for what purpose. When recommending or selling products ensure they meet these requirements.
Selling to the general public
If hazardous goods are sold to the general public they should be labelled with “Read carefully and follow all instructions” and “Keep out of reach of children”.
Any adverts for paints sold to consumers, which allows a member of the general public to order without first having sight of the label (e.g. from an on-line store),must mention any hazard information indicated on the paint label.
Selling to industrial or professional users
If selling hazardous paints to industrial or professional users, they should be provided with a SDS pro-actively.
SDS are required by industrial and professional users to advise on the safe use of the product.
Sales to GB (England, Scotland and Wales)
Sales to GB are governed by UK REACH and GB CLP. The supplier’s address on the label must be in GB.
Sales to NI and the EU
Sales to NI and the EU are governed by EU Regulations. You must have a supplier located within the EU or NI and their address must be on the product label and SDS.
Blending of paints
If you blend paints, you become a user, rather than a distributor of the paint. You must make sure that the blended paint is classified, labelled and packaged correctly and that an SDS is available for the blended paint.
Is the paint hazardous?
If the paint is labelled with CLP symbols like those shown below, it is hazardous.
You must supply a safety data sheet (SDSs) to professional or industrial users prior to or along with supply of the product.
Is the paint dangerous goods for transport?
Goods carrying transport labels like those shown below, are dangerous goods, DG, for transport.
If transporting or consigning Dangerous Goods your must have a Dangerous Goods Safety Advisor (DGSA).
Paints that are DG must be packaged, marked and labelled according to the method of transport and the product’s UN number.
Packaging and Labelling
Paints bought from the manufacturer should be labelled and packaged correctly. The packaging and labelling, including outer UN approved packaging from combination packages containing DG should be preserved, unless road derogation 4 applies.
Can the Paint be transported in Limited Quantities, LQ?
Some DG can be transported in LQ. DG packed in LQ must be marked with the LQ mark.
Goods packed in LQ are not subject to the full provisions of the Regulation. Goods in LQ must be packed in inner packages placed in suitable outer packagings. There is a maximum quantity per inner package depending on the UN number of the DG and a maximum gross mass for the outer package. Consult your DGSA for further advice.
Can I split inner packagings from their outer box?
The UK Road Derogation 4 for retail distribution may apply. Consult your DGSA.
Orientation Arrows
Outer packagings containing liquid DG must be marked with orientation arrows.
If you ship DG, you must be trained to do so.
Labels
Products classified as hazardous under CLP must be labelled with the correct label elements.
Vehicle Refinish Paints
Vehicle refinish paints must comply with the Paint Directive and be labelled with the subcategory of the product and the maximum VOC content in the paint.
Aerosols
Aerosols must comply with the Aerosol Directive and be labelled with a batch code, net contents by weight and volume, (3) or UKCA mark, and precautionary statements. If you fill a pregassed aerosol with paint you might need to update the safety information on the aerosol.
Diisocyanates (inc 2 K Activators)
Products containing diisocyanates must contain the phrase “As from 24 August 2023 adequate training Is required before industrial or professional use”.
Drugs, explosives, poisons and offensive weapons regulations
Some paints and thinners are subject to other regulations including those related to explosives, poisons, drugs precursors and offensive weapons. Regulated poisons and explosive precursors must be labelled with “Acquisition, possession or use by the general public is restricted.”
Consumers do not need a licence to buy reportable explosive precursors and poisons, such as acetone, but you must still report suspicious chemical activity.
Hauliers & Carrier Restrictions
Ensure you comply with any requirements or restrictions imposed by the carrier you use. Many well-known carriers do not take DG. Some take goods packed in LQ, others do not. Royal Mail do not accept solvent borne paint; any water-borne paint must be packed in containers less than 150ml.
Do not ship by air, unless the goods are compliant with the air transport regulations.
Providing information to the haulier
Some shipments of DG may be shipped as “small loads” and do not require ‘orange plates’ on the vehicle or an ADR qualified driver. There is a limit on the amount of goods per vehicle; you must provide information on the dangerous goods to be shipped to the haulier.
